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PRIVACY POLICY privacy policy


Welcome to the Moore Law privacy policy (‘Policy).

We respect your privacy and are committed to protecting your personal data. This Policy will inform you as to how we look after your personal data, including when you visit our website (regardless of where you visit it from), or when you use our services, and tells you about your privacy rights and how the law protects you.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary below to understand the meaning of some of the terms used in this Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS POLICY

This Policy aims to give you information on how Moore Law collects and processes your personal data, including through your use of this website, and any data you may provide through this website, or when you contact us or sign up to our newsletters, instruct us to carry out any legal work for you or otherwise communicate with us or send us information.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together with the relevant paragraphs relating to data protection and privacy set out in our Engagement Letter in the event that you become a client so that you are fully aware of how and why we are collecting and processing and otherwise using your data. This Policy supplements the other notices and is not intended to override them.

CONTROLLER

Moore Law Limited is a private limited company registered in England and Wales under company number 07970298 with its registered office and main office address at Sussex Innovation Centre, University of Sussex, Brighton, East Sussex, BN1 9SB. We are the controller responsible for this website and your personal data. We are collectively referred to as “Moore Law”, “we”, “us” or “our” in this Policy.

Our Data Privacy Manager is responsible for overseeing questions in relation to this Policy. If you have any questions, including any requests to exercise your legal rights, please contact our Data Privacy Manager using the details set out below.

CONTACT DETAILS

Data Privacy Manager

Email: info@moore-law.co.uk

Telephone: 01273 704789

CHANGES TO THE POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated in May 2018 and may be subject to further revisions.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes: first name, maiden name, last name, marital status, title, date of birth and gender, passport or ID number, photos or other images.
Contact Data includes: home address, billing address, email address and telephone numbers, and any social media accounts used to contact us or register on our system.
Financial Data includes: bank account.
Transaction Data includes: details about payments to and from you and other details of services you have obtained from us or with a third party.
Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes: any username and password, or pseudonym used on our systems, or record of your interests, preferences, feedback and survey responses.
Usage Data includes: information about how you use our website, products and services.
Marketing and Communications Data includes: your preferences in receiving marketing from us.

Sensitive Data includes personal information about you which may be relevant to the services that we provide or which relates to your employment record etc. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.

Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a retainer we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services).

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our websites or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
• apply to use our services;
• request marketing to be sent to you;
• make a general enquiry about our services; or
• give us feedback.

Automated technologies or interactions. As you interact with our website or social media accounts, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Identity and Contact Data from publicly availably sources. Such as Companies House and the Electoral Register based in the UK.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the retainer contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Here is some GDPR guidance prepared by the Law Society on what measures law firms like us should take.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending you marketing communications via email. You have the right to withdraw consent to marketing at any time by Contacting us or by clicking ‘unsubscribe’ in any communication you receive from us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the below.

1. To register you as a new client and provide legal services to you

Type of data

Identity – Contact – Financial – Transaction – Profile

Lawful basis for processing

Performance of a contract with you – Necessary for our legitimate interests (for tax or legal liability purposes) – Necessary to comply with a legal obligation

2. To provide our legal a services including: – Manage payments, fees and charges – Pass your details to administrative or technology providers in order to perform our services. – Collect and recover money owed to us

Type of data

Identity – Contact – Financial – Transaction – Marketing and Communications – Profile

Lawful basis for processing

Performance of a contract with you or with a Customer – Necessary for our legitimate interests (for tax or legal liability purposes) – Necessary to comply with a legal obligation

3. To manage our relationship with you which will include: – Notifying you about changes to our terms or privacy policy – If you are a supplier to us, or have some other form of contractual relationship with us – Asking you to leave a review or take a survey

Type of data

Identity – Contact – Profile – Financial – Transaction – Marketing and Communications – Profile

Lawful basis for processing

Performance of a contract with you – Necessary to comply with a legal obligation – Necessary for our legitimate interests (to keep our records updated, to comply with our legal and tax obligations, or to study how customers use our products/services)

4. To enable you to complete a survey

Type of data

Identity – Contact – Profile – Usage – Marketing and Communications

Lawful basis for processing

Performance of a contract with you – Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

5. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

Identity – Contact – Technical

Lawful basis for processing

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) – Necessary to comply with a legal obligation

6. To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you

Type of data

Identity – Contact – Profile – Usage – Marketing and Communications – Technical

Lawful basis for processing

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

7. To use data analytics to improve our website, services, marketing, customer relationships and experiences

Type of data

Technical – Usage

Lawful basis for processing

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

8. To make suggestions and recommendations to you about our services that may be of interest to you

Type of data

Identity – Contact – Technical – Usage – Profile

Lawful basis for processing

Necessary for our legitimate interests (to develop our services and grow our business)

MARKETING

We only send you newsletters and law and practice bulletins because we think you might be interested in a particular service that we offer or you might find the information useful.

We will never sell your personal data to third parties and if we ever promote third party services in the content of our own marketing – which is rare – it is strictly on the basis that you have freedom of choice as to whether or not you engage with that third party in any way. We will never pass your details to them without your express consent nor have we ever been paid nor would we seek to be paid a commission or derive any other direct financial benefit in this regard.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out or unsubscribe’ links in any marketing message sent to you or by Contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in your capacity as a client or the legal services we provide you, as a result of a service or other transaction, or where we need to keep your contact details or make contact with you for contractual performance or legitimate interest purposes, or compliance with a legal obligation.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4.

• External Third Parties as set out in the Glossary or elsewhere in this Policy.
• Specific third parties listed in the Glossary or elsewhere in this Policy.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, consultants and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We seek to use third party technology providers that are ISO27001 certified or equivalent (SOC II) where practical.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our clients and employees (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax and legal liability purpose, but we also keep this information to make it easier for clients to give us new, follow-on or repeat instructions. We will notify you before we delete your personal data and whilst we are not under any obligation to do so we can, by arrangement, continue to hold it if you would like us to do so

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Consent means the unambiguous approval to use personal data in a specific way, it must involve a clear affirmative action (an opt-in). In relation to the use of Special Personal Data, the consent must be given expressly in relation to this use.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

EXTERNAL THIRD PARTIES

• Service providers acting as processors based in and outside the EU who provide IT and system administration services (for example, Mailchimp or our case management system Leap).
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services to us.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom or EU who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; © where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.